Deadline for filing first foreign ownership notifications is extended from 1 April 2015 to 15 June 2015

09.04.2015

On 6 April 2015, the President of the Russian Federation signed Federal Law No. 85-FZ “On Amendments to Article 219 of the Second Part of the Russian Tax Code and Article 4 of Federal Law “On Amendments to the First and the Second Parts of the Russian Tax Code (Regarding Taxation of Profit of Controlled Foreign Companies and Income of Foreign Organisations)"" ("the Law").

As we predicted in Legal update No. 502 on 10 February 2015, the deadline for filing first foreign ownership notifications under the Deoffshorisation Law has been extended:

  1. Russian tax resident individuals and companies have to file first foreign ownership notifications under the Deoffshorisation Law in relation their participations held as of 15 May 2015 no later than 15 June 2015 instead of 1 April 2015;
  2. no notification should be filed if participation in a company is terminated or if a structure, such as trust, is liquidated during the period from 1 January 2015 to 14 June 2015 inclusively;
  3. no liability applies for failure to file foreign ownership notifications by 1 April 2015 (RUB 50,000 for each failure to notify about a participation).

The Russian Federal Tax Service is yet to finalise and approve the notification forms and filing procedures; however, their final approval and publication is expected in the coming months.

How Goltsblat BLP can help:

  • Pre-disclosure review of companies and structures for the purposes of full compliance with the Deoffshorisation Law;
  • Advice to companies and individuals on complex issues of filing foreign ownership notifications with respect to multi-layer corporate structures with indirect participation;
  • Coordination of mandatory disclosure under the Deoffshorisation Law with voluntary disclosure under the "capital amnesty" law; and
  • Corporate restructuring to reduce tax-related risks under the Deoffshorisation Law, simplify corporate structures and, if necessary, to return equity ownership of business enterprises to Russia.

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Ksenia Soboleva

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